Memorandum submitted by Paul Shabajee and Sarah Raynes
· Significant and clearly evidenced concerns over quality, thoroughness, unthought-though implications and bias.
· Fundamental lack of research base on which to base such sweeping changes
· Omissions of home-educators or experts in home-education from the review team
· Clear indications of bias towards pre-determined outcomes
· No risk assessment of the recommendations or analysis of potential un-intended consequences of the recommendations
· Lack of validation of the recommendations
· Apparent presumption of 'guilt' - sweeping and unfounded changes in relationship between parents and the state
· Lack of consultation with or voice of children.
· Confusing school-targets with education & learning
1. Context: Having read the report and
many comments and thoughts from other interested parties, we have significant
concerns about the quality, thoroughness, apparent lack of understanding of the
implications and apparent bias implicit in the report. Many other issues are
raised in other submissions that we are aware of and we have therefore focused
on a number that have not been more widely raised.
2. Lack of research base and grounded evidence:
The report makes recommendations that require changes to fundamental
legislation, dramatic changes in the role of Local Authorities (LA) in relation
to home-educators and their children, and may significantly undermine many of
the most positive aspects of 'education otherwise than school' and yet these
recommendations are based (on the basis of the evidence in the report itself)
on very little validated research evidence.
3. Makeup of the review team: As we
understand no member of the review team was directly associated with home
education. This is a very odd decision, rather like reviewing school education
without having anyone who had taught in schools (or even been a student) on the
review committee. Were the situation reversed we doubt this would be seen as
acceptable or valid.
4. Bias: There are a large number of
places where there appears to be bias towards a predetermined outcome. Examples
include, limited direct quotes in the report of home-educators or organisations
that represent home-educators compared to emphasis given to the views of some
organisations, e.g. Section 4.7 and 4.8 that while they are associated with
school or church-based education, they have no a priori expertise or even
knowledge of the actual practice of home education; there is certainly no
evidence of such in the report. It is unclear why these views are given such
5. No mention of risks or potential negative
impacts of the recommendations: There appears to have been no assessment of
the potential impacts of the recommendations beyond those the 'desired'
outcomes. Specifically there does not seem to have been any risk assessment or
analysis of the potential negative unintended
consequences of the recommendations.
· there seems to be a serious risk that the recommendations will undermine the many positive aspects of home education and so creating a reduction in the quality of education for 1000s of home educated children, e.g. the report states that "I have met some extraordinarily accomplished young people who have prospered as a consequence of elective home education of whom their parents are justly proud, ...", and yet does not re-visit this situation in the context of the recommendations.
· it possible that the recommendations will inadvertently force some children and their families into distressing and negative situations
· there a risk that already scarce resources will need to be moved from other child services to pay for what must be an expensive and administratively complex system, thereby taking resources from high risk area to one with a relatively lower risk.
· Are there any aspects of the recommendations that might increase the risk to children? The answer is logically yes, of course scenarios can be imagined where this would be the case, the question is have those risks been identified and assessed?
· what are the risks to children if Local Authorities implement the
recommendations poorly or if individual Local Authority officers are
antagonistic, in some reasons and particularly supportive to home-education in
others, leading to different regions of the
6. Lack of validation of the recommendations:
It is unclear that the review team have conducted a 'reality check' on their
7. Apparent presumption of guilt: one recommendation
that seems particularly poorly thought through is the recommendation 7.
- have the right of access to the home;
- have the right to speak with each child alone if deemed appropriate or, if a child is particularly vulnerable or has particular communication needs, in the company of a trusted person who is not the home educator or the parent/carer.
In so doing, officers will be able to satisfy themselves that the child is safe and well."
This is a fundamental change to the relationship of parents (indeed
citizens) with the state and is based on the assumption that without any cause
for concern whatsoever the government official has right of access to a child
alone. This is not appropriate and proportionate to the risk. We understand
that no other authorities have such powers.
The report notes that "... the number of children known to children's social care in some local authorities is disproportionately high relative to the size of their home educating population.", as evidence for the need for such measures is wholly inappropriate since it is very to be expected that many children will have been home-educated by their parents precisely because they have needs and problems that the parents believe that school is not able to support effectively.
Indeed the fact of involvement of support services, may indicate that parents are responsibly making use of the services to the benefit of their children disproportionately to the general population.
Without analysis of the underlying reasons it is far from clear. The review team provide no analysis of the reasons for families being 'known' while this would no-doubt have been possible.
Many have pointed out that a logical conclusion of this thinking is that all families with pre-school children should be assessed in a similar way, a fact mentioned by the report itself (8.1). Would such a scheme be seen as acceptable or appropriate?
The review team seem not to have understood the enormity of the
implications of this recommendation.
8. Lack of consultation with or voice of
children: The voice of children in the document is noticeable only by its
almost complete absence! The views, thoughts, feelings and underlying needs of
individual children is seen by many, probably the majority of, home educators
as central to decisions about their learning and their well being. Indeed it is
a fundamental part of the philosophy of education of many home educators. The
fact that this report does not apparently give them a significant voice in this
discussion is perhaps indicative of the fact that they those behind this report
do not share that view?
9. Confusing school-targets for education
& learning: There appears to be a very significant lack of
understanding of educational approaches used by home educators and their
children, e.g. child-centered, personalised, responsive, informal
learning. In particular recommendation 1 includes; "At the time of registration
parents/carers/guardians must provide a clear statement of their educational
approach, intent and desired/planned outcomes for the child over the following